Confined Space Safety –Best

Practices and Training Overview

Guy R. Colonna, P.E.
NFPA
API Storage Tank Conference
Tulsa, OK
September 27, 2006

Presentation Overview
•Introduction
•Confined Space Safety
–Hazards
•Recent incidents
•Systems Approach
–Recognition
–Evaluation
–Control

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Presentation Overview
•Industry Best Practices
–API 2015 and 2016
–NFPA 326
•Atmospheric Monitoring
•Safe Tank Entry - Confined Space Training
Program
•Tank Entry Supervisor Certification
•Safe Tank Alliance –API, NFPA, STI and OSHA
•Closing remarks, Questions

Confined Space Incidents

What Happened?
•Documented in a series of OSHA Reports
in the mid-
mid-80’
80’
s
•Atmospheric - approximately two-
two-thirds
–Toxic and asphyxiating
–Fires and explosions
•Physical - approximately one third
–Slips, trips and falls
–Other
•Experience remains similar today!

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 Hot Work

Two workers suffocate at refinery

Maintenance men were not authorized to enter nitrogen-filled
tank
By JEFF MONTGOMERY
The News Journal
11/07/2005
Two contract workers suffocated early Sunday at the Valero
Energy Corp. refinery near Delaware City after they
entered a nitrogen-filled area inside a tank.

Valero spokeswoman Mary Jen Beach said Sunday that the two
contractor employees were not authorized to go into the
roughly 40-foot-tall vessel, although they were assigned to work in
the same area.

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 Triple Fatality at Mississippi Work Site
Results in OSHA Citations for Oil and Gas
Service Company

JACKSON, Miss. -- The U.S. Department of Labor's

Occupational Safety and Health Administration (OSHA)
has cited Stringer Oilfield Services and proposed
penalties totaling $40,300 following the investigation of
a fatal accident at a Raleigh, Miss., work site.

The accident occurred on June 5 as employees welded

pipes connecting used oil storage tanks.

Vapors in one tank that contained oil residue traveled

through the piping. Sparks then ignited the vapors.
Subsequent explosions and fires resulted in the death of
three workers and the hospitalization of another.

Factors Contributing to Confined Space

Fatalities
•Failure to recognize confined spaces
and the dangers
•Underestimate the danger
•Trust the senses
•Become complacent
•Attempt to rescue their buddy

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Industry Reacts
•OSHA Permit-
Permit-Required Confined Space
Standard –29 CFR 1910.146 (1993)
–Defined confined space
–Defined hazards
•Industry specific best practices
–API 2015
–API 2016
–NFPA 326 –first edition 1993

Pre-Inventory

1. A confined space has the following

characteristics:
a) Not intended for continuous occupancy
b) Effectively ventilated
c) Extremely small opening
d) Limited access or egress
e) Large enough to permit entry and work
f) Contains dangerous air contaminants

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Pre-Inventory

2. Oxygen deficiency occurs as a result of:

a) Rusting
b) Inerting
c) Organic decomposition or decay
d) Fire
e) All of the above

Pre-Inventory

3. Two factors that might change a safe

condition and prompt re-
re-testing of the
atmosphere in a confined space:
a) Temperature
b) Size of the openings in the space
c) Nature or type of work in the space
d) Size of the space

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Pre-Inventory
4. Oxygen sensors should be changed on
average approximately
a) every year
b) every 2 weeks
c) every 3 years
5. The minimum safe level of oxygen is
a) 23.5%
b) 21%
c) 19.5%

Pre-Inventory
6. Calibration checks should be performed
a) monthly
b) Daily, prior to use
c) Annually
7. Two physical hazards include
a) entrapment
b) low oxygen
c) carbon monoxide
d) engulfment

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Systems Approach to Confined
Space Safety
•RECOGNITION - Identification of spaces
and hazards (atmospheric or physical)
•EVALUATION - Confirm the presence of
hazards (atmospheric or physical) and
assess the severity
•CONTROL - Action taken to eliminate or
minimize the hazards: engineering,
administrative, or personal protection

Recognition
“
Hazard Identification & Risk Assessment”
Assessment”

•Identification of Spaces According to

Definition
•Identification of Hazards
–Atmospheric (oxygen, flammability, toxicity)
–Engulfment
–Entrapment
–Other physical or mechanical (energy sources,
heat stress, noise)

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Evaluation
“Confirm or Deny Presence of Hazards and Determine
Severity”
Severity”

•Qualitative Assessment
–Use MSDS, other reference sources, and
senses
•Quantitative Assessment
–Measurement of atmospheric components;
compare test results to established standards
to determine whether a safe condition exists

Control
“
Action taken to eliminate or minimize hazards”
hazards”

•Engineering •Personal Protective

–Ventilation –Protective Clothing
–Isolation –Respiratory Protection
–Substitution –Follow-
Follow-up atmospheric
•Administrative monitoring
–Safe Work Practices –Emergency and rescue
–Permits
–Training

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Systems Approach to Confined
Space Safety
•ENTRY - Requires the proper identification
and evaluation of the hazards by qualified
individuals prior to initial entry
•WORK - Requires an understanding of the
potential for the work to alter existing
conditions and requires appropriate
controls to be administered
•EXIT - Requires provisions for routine and
emergency exit from all spaces

What is a Confined Space?

•Characteristics include:
–Limited access and egress
–Not intended for continuous occupancy
–Inadequate ventilation
–Contains or potential to contain hazards

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OSHA Definition
29 CFR 1910.146
A confined space must have these
characteristics:
•Large enough and so configured to permit
entry and work
•Not designed for continuous human
occupancy
•Limited or restricted means of entry and
exit

Permit-Required Confined
Space (PRCS)

Is a confined space that contains or

may contain:
•Hazardous atmosphere (oxygen content,
flammable, or toxic)
•Engulfment hazard
•Entrapment hazard
•Other recognized serious safety hazard –
energized electrical equipment, noise,
heat stress

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Confined Space Example –Diked
Area

Additional Confined Space Hazard –

Pontoon (hollow structures)

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 Is this a confined
space?

Designated Personnel
•Entrant
•Attendant
•Entry supervisor
•Qualified atmospheric tester
•Rescue and emergency services

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Designated Personnel - Entrant

•Trained to recognize hazards

•Trained to use PPE as required
•Communicate with attendant as necessary
•Recognize symptoms of exposure
•Understand principles of self-
self-rescue

Designated Personnel -
Attendant
•Remain outside space at all times
•Trained to recognize hazards and
exposure symptoms
•Communicate with entrants
•Communicate alarm, evacuate if necessary
•Monitor more than one space at a time
•Prevent unauthorized entrants
•Alert to changing conditions

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Designated Personnel - Entry
Supervisor
•Trained to recognize hazards
•Authorizes entry based upon hazard
assessment, identify acceptable conditions
•Verify emergency plans and rescue
personnel availability
•Revoke permit if conditions change
adversely
•Terminate permit at job completion

Designated Personnel - Qualified

Atmospheric Tester
•Responsible for conducting atmospheric
monitoring
•Trained to properly select, calibrate, use
and maintain all required instruments
•May be any of the key personnel - entrant,
attendant, supervisor

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Qualified Testers
•Knowledge of confined spaces and typical
hazards
•Ability to use, calibrate, and maintain
testing instrumentation
•Ability to interpret results

Qualified Testers
•Familiarity with regulations, standards,
and/or appropriate guidelines
•Familiarity with structure and
configuration of confined spaces
•Ability to perform tests and record
results

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Designated Personnel - Rescue and
Emergency Services
•Either on-
on-site or off-
off-site permitted
•Trained at least as entrants and in use of
rescue equipment
•Trained in basic first-
first-aid/CPR and at least
one member certified in both
•Conduct annual drill
•Coordination between employer and off-off-
site provider

API 2015, Requirements for Safe Entry and

Cleaning of Petroleum Storage Tanks

•Scope and Applicability

–Applies to atmospheric and low-
low-pressure
aboveground petroleum storage tanks
–Includes decommissioning, hazard assessment,
permit entry and work system, emergency planning,
and recommissioning
–Does not apply to pressure vessels, process vessels,
underground storage tanks
•Industry specific application of OSHA
requirements in 29 CFR 1910.146

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API 2016, Guidelines and Procedures for
Entering and Cleaning Petroleum Storage
Tanks
•API 2015 –what must be done to ensure
process of cleaning, entry, and work can
be done safely
–Must comply with minimum federal standards
•API 2016 –supplements API 2015
providing guidance and information on
specific aspects of tank cleaning
–Offers guidance on “
how”
how”to do what API
2015 requires

NFPA 326, Safeguarding of Tanks and

Containers for Entry, Cleaning, or Repair

•Scope and Purpose

–Safe opening, entry, and cleaning
–Safe removal of flammable, combustible, or
other hazardous substance vapors, liquids or
solid residues
–Minimum procedures permitting repair, hot
work or other operations with potential to
create a fire, explosion or other hazard

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Atmospheric Hazards –Where do
they come from?
•Product, Process or Reactivity
–Cargoes or other stored products
–Paints or coatings
–Cleaning solvents
–Leaking acetylene torches
–Oxidation
–Decomposition of organic materials
–Hot work - welding, cutting or burning
–Leaking pipes

Testing Frequency
•Temperature
•Nature of the work in the tank
•Period of time elapsed
•Unattended tanks
•Work break
•Product –highly volatile flammable or toxic

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Training Areas For Atmospheric
Testers
•Observed Calibration / Function
Checks
•Theory of Operation for Instruments
•Instrument Limitations
•Acceptable Test Results

Training Areas For Atmospheric

Testers
•Testing Techniques
•Record Keeping
1. Calibration Log
2. Entry/Hot Work Permit
•Observed Testing Simulations
(Calibration Check, Function Check,
Testing, Permit Preparation)

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Calibration
•Calibration Check/”
bump”test
–Expose oxygen, combustible or toxic
sensor to known concentration of
sample gas
–Compare meter reading to known gas
concentration
–Adjust as necessary
•Calibration check prior to use each
day

Calibration

•Function Check
–Breathe into oxygen sensor, check for
deflection
–Expose combustible sensor to source, check
for deflection
–Not quantitative, but shows that instrument is
functioning
•Function check frequently during use
•Determine response time of instrument

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Evaluation of Atmospheric
Hazards and Residues

Residues
Requires a Visual Inspection once
Atmospheric Hazards have been
eliminated

Safe Tank Entry Training Program

•Collaboration between API and NFPA

•2-day seminar focused on confined space
hazard recognition, evaluation and control
•Incorporates requirements and best
practices from OSHA, API and NFPA
•Emphasis on atmospheric hazard
assessment and control through hands-
hands-on
use of state-
state-of-
of-the-
the-art monitoring devices
•API Tank Entry Supervisor certification

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Safe Tank Entry Seminar Outline
•Systems Approach –Recognition,
Evaluation and Control
•Hazard Awareness –case studies and
lessons learned (activity)
•NFPA Confined Space Safety video
•Administrative Controls –regulations and
standards
–OSHA 29 CFR 1910.146 –PRCS program
–API 2015 and 2016

Seminar Outline - continued

•Hazard evaluation
–Theory and operation of instruments
•Hands-
Hands-on applications –skill assessment
–Instrument calibration and function checks
–Entry and work simulations
–Permit preparation
•Post inventory –knowledge assessment

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API Tank Entry Supervisor

•Certification program launched in 2004

•NFPA Safe Tank Entry training program is
not designed as preparation course for
TES exam
–The elements for TES certification include
many of those areas covered within NFPA
training
•Exams offered twice each year at various
locations

Job Analysis - 7 Activity Areas

•Project Planning (not including field

work)
•Tank Preparation
•Ventilation and Atmospheric Testing
•Entry for Inspection and Work Planning
•Tank Cleaning
•Entry for Repairs and Modifications
•Returning to Service

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 Safe Tank Alliance
•Cooperative Partnership with industry and OSHA
–Initiated in March 2004 with API, NFPA, OSHA
–Renewed in September 2006 –STI added to team
•Focus on Outreach and Education
•Safe Tank Alliance Best Practices Workshop
–Held at a Company Location
–Best Practice Sharing and Networking
•Entry and Hot Work brochures - NFPA
•OSHA E-
E-Tool on Safe Tank Entry
•Safe Tank Entry Workshop –NFPA training
•OSHA Website: www.osha.gov

Questions?

gcolonna@nfpa.org

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